S. 147 : Reassessment-Notice-Failure to respond notices-Natural justice is not violated-Division bench held that the Single judge right in relegating assessee to remedy of statutory appeal Extension of time granted to file appeal before appellate authority-Stay of coercive proceedings until outcome of order in statutory appeal.[S. 148, 246A, Art. 226]

S.147: Reassessment-After expiry of four years-No failure to disclose material facts-Change of opinion-Dividend from trust-Investment allowance wrongly claimed-Reopening invalid. [S. 2(22)(e), 10(34), 32AC, 143(3), 148, Art. 226]

S. 147: Reassessment-Foreign assets-Notice issued pursuant to liberty granted by Supreme Court relating to foreign assets-Supreme Court decision in first round of litigation binding on parties Sufficient material existed to justify reassessment-SLP dismissed-Corporate guarantee the issue is kept open. [S. 68, 92B, 147, proviso (ii), 148, Art.136, 142]

S. 144C : Reference to dispute resolution panel-Objections raised by assessee must be considered before order is issued-Order passed without waiting for directions of Dispute Resolution Panel on assessee’s objections Liable to be quashed Assessing Officer to await directions of Dispute Resolution Panel. [S. 144C(5) 144C(6) 144C(10) Art.226]

S. 144C : Reference to dispute resolution panel-Assessment order-Limitation-Assessment orders passed beyond period prescribed in S.144C(13) invalid and set aside-Interpretation-When the language of the provision is clear, no external aid of interpretation is required.   [S.144C(13), Art. 226]

S. 144B : Faceless Assessment-Standard Operating Procedure Period of seven days must be given to respond the notice-Order is quashed and set aside [S. 144B(6)(xi), Art.226]

S. 144 : Best judgment assessment-Books of account not rejected-Based on departmental valuation Officer’s report-Reference made under section 142A by the Assessing Officer to the Departmental Valuation Officer was not in accordance with law-Order of Tribunal affirmed. [S. 142A, 145, 260A]

S. 143(3): Assessment-Amalgamation-Assessment order passed in name of non-existent assessee amalgamated company after informing Department duly informed about merger-Participation in proceedings no estoppel against law-Assessment order quashed and set aside.[S. 144B, 144C, Art. 226]

S. 143(3): Assessment-Firm-Additional capital by partners-Fund flow established-Matter remanded to the Assessing Officer to consider the additional documents provided by the assessee. [S. 68, 142(1), Art. 226]

S. 143(3): Assessment-Principles of natural justice-Covid-19 pandemic-Not granting sufficient opportunity-Matter remanded to Assessing Officer to consider afresh after giving due opportunity to assessee.[S. 144B, Art. 226]